Advocacy was sometimes undertaken jointly with the growing number of civil society organisations (CSOs) with an interest in digital rights and/or companies, particularly members of the Global Network Initiative. GNI member companies were keen to work collectively with MCRB to pursue rights-protecting regulatory reform as they recognised that the legal framework could prevent them from meeting their responsibility to respect human rights. This concern became a reality for Telenor and contributed to its decision in July 2021 to exit Myanmar. An explicit requirement to install interception equipment was placed on all mobile operators prior to the 1 February 2021 coup. Following the coup, heightened human rights risks associated with assisting surveillance amidst 2018 EU and Norwegian sanctions on surveillance equipment led Telenor to exit Myanmar. MCRB made written submissions to consultations. based on the UNGPs, on draft secondary legislation on issues such as mandatory SIM Card registration, and internet gateway services guidelines, with comments focussed on the privacy/data retention aspects of the proposal. MCRB also submitted comments on the 2015 draft Telecommunications master plan covering issues such as transparency, universal access and service, data privacy and responsible business conduct, having successfully encouraged the Ministry to undertake an open consultation process. It should be noted that the Ministry of Telecommunications (later Transport and Communications), perhaps due to support on Telecoms Sector Reform from the World Bank, was generally more systematic in seeking comments on draft regulation and policy than other Ministries. The main responders to consultation were the business community, not least due to the lack of civil society focus on, or understanding of, the sector until recently. MCRB sought to encourage the widest possible input whenever a consultation was announced. MCRB and other organisations also conducted written and in-person advocacy, towards the Parliament in September and October 2016, which had drafted (without regulator input) a Citizen’s Privacy and Security Protection Law. Advocacy was focussed primarily on the need for safeguards on lawful interception. This was treated as little more than one line in the law, and therefore failed to provide the necessary safeguards and oversight. During the 2016-2020 period, MCRB also sought, with others, to engage on the draft ‘hate speech’ law although the opaque policy and regulatory process made this challenging. MCRB participated in consultations in Naypyidaw in January 2019 on a draft cybersecurity framework, combining this with a briefing for relevant parliamentary committees on digital rights issues, and legislation and policy gaps. (The evolution of this regulatory framework is charted on MCRB’s website, including the latest consultation draft circulated in January 2022). In all this advocacy, the three-pillar framework of the UNGPs was always used to help stakeholders understand the respective roles and responsibilities of government and business, since regulators and legislators were often unfamiliar with business and human rights. Multistakeholder approach to policy and regulation – Myanmar Digital Rights Forum To build awareness of digital rights issues (mainly freedom of expression, privacy and access/inclusion) and to promote multistakeholder dialogue, MCRB was one of the instigators and co-hosts of the Myanmar Digital Rights Forum. This was first held in December 2016 and again in 2018, 2019 and February 2020, with support from the Swedish government. Several hundred participants attended, mainly from business and civil society, as well as international experts and development partners. Although there was some participation from government officials who were given speaking roles, there was very little participation from MPs. Indeed, finding MPs who were interested in digital rights remained challenging. Generally the conclusions of the Forum highlighted the need for digital policy and regulation that protects human rights. MCRB and MDRF co-organisers sought to bring this to the attention of regulators and legislators following the Forums. Sensitivity: Open